Capital Edge’s Tip Line #11: CAS Board Discussions
August 21, 2025
Capital Edge Tip Line – August 21, 2025
CAS Board Discussions – Edition 11
In this week’s Capital Edge Tip Line, CEO Chad Braley dives deeper into the ongoing CAS Board Discussions and the areas that Capital Edge has followed and commented on during the open public period.
Key Updates from This Week’s Tip Line
CAS Board Discussions – What You Need To Know
What’s happening? CAS Board Discussions are underway and we're here to provide updates based upon what we've followed and commented on during the open public period.
What's being discussed?
Statutory Threshold: Right now, the base CAS contract value of $2 million is tied to the same threshold used for Truthful Cost or Pricing Data (formerly known as TINA). The proposal would decouple them, with CAS having its own threshold, and TINA its own. There’s also talk of raising the TINA threshold beyond the scheduled inflation adjustment set to go into effect this October.
Regulatory Threshold: There are rumblings that the CAS coverage threshold may jump from $50 million to $100 million. The current $7.5 million “trigger contract” value could be eliminated altogether. And the CAS-covered minimum value, currently $2 million, could rise to $10 million or even $25 million. These potential updates echo recommendations from the Section 809 Panel and other policy groups.
Conformance to GAAP: The CAS Board is continuing its push to align certain standards more closely with GAAP. The key question is whether these areas are already adequately addressed in FAR 31 and GAAP, making CAS redundant.
In active review now are four standards:
404: Capitalization of Tangible Assets
408: Compensation for Personal Absence
409: Depreciation
411: Acquisition Cost of Material
Three more are under consideration for removal or revision:
407: Standard Costs for Direct Labor and Materials
415: Deferred Compensation
416: Insurance Cost
Cost Impacts: There’s discussion of a potential FAR deviation related to 36.003, in light of the 2023 NRD memo following the Raytheon case. That memo’s Scenario 2 contradicts the court decision and is viewed as unfavorable to contractors. Many are hoping for clearer alignment between CAS cost impact rules and the statute.
CAS to Indefinite Delivery Contracts: This is an area we directly commented on during the open public period. The push is to apply CAS thresholds at the task order level, not at the total IDIQ value. That shift would help avoid the flawed assumption that a $200 million contract split across multiple vendors should automatically trigger CAS. One proposal suggests a $25 million threshold, still high enough to exempt most task orders, while keeping high-value contracts covered.
What this means for you:If these proposed CAS updates move forward, they could ease the compliance load for many contractors while keeping meaningful oversight in place. Discussions are underway and we’ll continue to monitor developments and keep you informed.
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